The British Hen Welfare Trust (BHWT) is a national
charity that encourages support for the British egg industry.
Its ultimate aim is to see consumers and food manufacturers buying
only UK produced free-range eggs, resulting in a strong British
egg industry where there is a willingness to continue to improve
welfare standards for laying hens.

The British Hen Welfare Trust (BHWT) supports British
egg farmers farming to high welfare standards, and wishes to see
farming remain strong in the UK where there is a willingness to
continue to improve welfare standards for laying hens.

We support the EU welfare of laying hen's directive
but are concerned that following its implementation:

 (a) the
EU will see increasing imports of egg powder from eggs laid in
conventional cages in non-EU countries; and

 (b) eggs
produced in non-compliant systems within the EU will continue
to be used in the production of multi-ingredient foods and available
to UK consumers.

To protect UK farmers from both cheaper imports,
and non-compliant farmers from outside of the UK, we recommend
the implementation of a production method labelling scheme for
multi-ingredient foods containing eggs. Such a scheme will empower
consumers with information to make informed purchasing decisions
based on animal welfare, and support UK egg producers farming
to higher welfare standards than non-EU farmers, and non-compliant
farmers in the EU.

1. In 2004 an EU Commission report estimated
24% of EU eggs are used in food processing and a further 20% go
to the food service sector. Multi-ingredient foods containing
eggs are not required to be labelled with egg production method.
This makes it difficult for consumers to distinguish between multi-ingredient
foods containing eggs raised through different production methods.

2. Following the implementation of the EU welfare
of laying hen's directive we are concerned the EU will see increased
imports of eggs and egg derivatives produced from conventionally
caged hens outside the EU. This trend is supported by predictions
made by the International Egg Commission. Professor Hans-Wilhelm
Windhorst, statistical analyst at the IEC has said "Egg production
in the EU declined by 2.5% from 2002 to 2007," and warns
the EU flock will continue shrinking, resulting in the EU becoming
a net importer for the first time by 2012.

3. Industry figures presented by the British
Egg Industry Council to the European Commission provide evidence
that it is cheaper to produce egg powder in countries outside
of the EU and export to Europe than to produce within the EU.

To produce a kg of whole egg powder (post 2012) in
the EU is estimated to cost 533 eurocent (including production
and transport). The costs in other countries (production, transport
and EU Import levies) are lower (Eurocent/kg).

 Argentina
= 499

 US
= 529

 Brazil
= 511

 India
= 486

This situation has potential to be further exacerbated
if talks within the WTO lead to a reduction in the import levies
which would effectively make overseas production even cheaper.

4. We are concerned that the reduction in egg
supply across the EU following the ban and the availability of
cheaper imports of egg powder will lead food processing companies
and the foodservice sector to import egg powder and multi-ingredient
products containing eggs produced by hens housed in conventional
cages in non-EU countries.

5. The EU egg industry estimates 29.3% of EU
egg farmers will be non-compliant from 1 January 2012. This accounts
for 83 million eggs per day which will no longer be marketable
within the EU. It is anticipated these eggs will be graded as
class B and used in processed foods.

6. The availability of non-compliant eggs and
the threat of cheaper imports of egg powder produced by hens in
conventional cages outside of the EU threaten the UK egg industry
which has invested in excess of £400 million so far in new
production systems to meet the conditions of the welfare of laying
hen's directive.

7. To counteract these developments we recommend
the implementation of a production method labelling scheme for
multi-ingredient foods containing egg product in the UK to empower
consumers with the information they require to make decisions
based on the welfare of animals.

8. Empowering the consumer will have immediate
benefits to the UK egg industry, providing an incentive to processing
companies to source eggs from higher welfare production systems
in the UK to meet consumer choice and provide themselves with
a marketable advantage.

9. In 2006, the Farm Animal Welfare Council stated:
"If retailers were required to label clearly the welfare
status of all livestock products it is possible that a significant
switch by consumers to products produced to higher animal welfare
standards would result". In addition, euro barometer surveys
on animal welfare show clear aspirational preference from the
British consumer for products produced to higher welfare standards.
For instance 87% of 45,000 consumers surveyed felt that food retailers
do not provide enough information on welfare conditions and 89%
felt that clearer labelling on livestock production methods should
be provided to indicate animal welfare condition.[5]
However these preferences and aspirations can only be translated
into purchase decisions if provision of transparent and clear
labelling is present.

10. During a recent stakeholders meeting in Brussels,
representatives of the Netherlands government proposed the implementation
of "a method" for consumers to distinguish between multi-ingredient
foods containing eggs from conventionally caged hens and those
containing eggs from higher welfare productions systems which
meet the EU directive. Therefore providing support for a production
method labelling for multi-ingredient foods containing eggs at
a European level.

11. A number of British retailers have already
committed to using eggs from non-caged hens in their own brand
products. Morrison's, Waitrose and M&S have also expressed
support to the BHWT and the BEIC for the development of a voluntary
production method labelling scheme for products containing eggs
in the UK.

 Ensuring
consumers can choose to support farmers farming to higher welfare
standards than non-EU farmers and non-compliant farmers in the
EU.

UK farmers

 Improving
consumer choice will see an increasing number of consumers demonstrating
a preference for higher welfare multi-ingredient food products.
This will subsequently lead to processing companies purchasing
eggs from higher welfare systems and help support egg farmers
farming to higher welfare standards.

 Providing
an additional platform to show consumers their support for UK
egg producers farming to higher welfare standards, and their commitment
to improving the welfare of egg laying hens.

 Providing
a marketable advantage over foods produced using eggs from conventionally
caged hens.

Animal welfare

 Empowering
consumers with information on the welfare standards of their foods
will lead to an increase in foods containing higher welfare eggs
being purchased. This in turn will provide producers with a powerful
incentive to produce welfare friendly products and retailers to
source them, providing farmers with the incentives to continue
to improve standards of animal welfare on farms and so improve
the individual welfare of egg laying hens.

 Farmers
and producers agree that market success of animal welfare schemes
will improve conditions for animals on the farm. Consumers play
a big role in determining the extent to which conditions improve;
the more animal welfare-friendly products consumers buy, the better
the conditions will be for farmed animals.[6]